International Tax Lunch: Inbound Executives of Foreign Corporations Webcast | 4193824A

Date :
December 13, 2019 12:00 PM - 1:00 PM
Location :
Facility :
Webcast Remote
Level of Difficulty :
Member Price :
Nonmember Price :
CPE Credits :
CPE 1.00, MCLE 1.00, IRS-TX 1.00, MCLE LS-TX 1.00
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Tax planning gets complicated when you are working with a nonresident coming to the U.S. to work for a while. You need to plan for the transition from nonresident to resident (with different rules for income tax and estate/gift tax), a period of years while the individual is a U.S. resident, followed by an expected return to nonresident status.

Identifying the issues early helps you to minimize tax costs and U.S. tax compliance costs. This session will walk you through the questions that come up—and how to address them—when a foreign executive or other individual comes to the United States as a long-term but temporary resident.


  • Identify actions to take before the individual becomes a U.S. resident in order to minimize U.S. income tax and U.S. income tax return complexity.
  • The transition years: when does residency start? How do you prepare the tax return for the year of transition from nonresident to resident, or resident to nonresident?
  • What type of estate tax and gift tax planning is appropriate and how do the rules work while they are living in the United States?
  • The importance of getting the "right" type of visa: why a green card creates tax risks. 

Major Subjects:

  • Definition of "resident" and "nonresident" for income tax and estate/gift tax.
  • Starting and ending dates for resident status.
  • Use of tax treaties and the closer connection test to control resident/nonresident status.
  • Expatriation tax rules as they apply to green card holders.
  • Reporting requirements for PFICs, CFCs, and foreign trusts.

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Designed For:

Lawyers and CPAs.


Philip D.W. Hodgen, Esq, Esq.
Philip D. W. Hodgen is the principal attorney for HodgenLaw PC, which specializes in the international tax arena. He earned his bachelor’s degree from Claremont McKenna College and his juris doctor degree from the School of Law at the University of California, Los Angeles. He went on to earn a master of laws in taxation from the University of San Diego School of Law. For six years as a youth, he lived in Rhodesia, South Africa and New Zealand. Admitted to the California Bar in 1982, Hodgen spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991. He is a past chair of the International Tax Committee of the State Bar of California’s Tax Section, and was a member of the Executive Committee of the State Bar of California’s Tax Section from 2004-07. He is on the Organizing Committee for CalCPA’s International Tax Conference and its annual Tax Update and Planning Conference. Hodgen frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, bankers, and real estate professionals.
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